Data protection notice
We take the issue of data protection and confidentiality very seriously and follow the provisions of the General Data Protection Regulation (“GDPR”) and applicable national data protection regulations. Please read this data protection information carefully before you submit a report.
Purpose of the whistleblowing system and legal basis
The whistleblowing system (BKMS® System) is used to receive, process and administer notifications of violations of the compliance requirement of Franklin Foods, Inc. (hereinafter: Franklin) in a secure and confidential manner. The processing of personal data within the framework of the BKMS® System is based on the justified interest of our company in the detection and prevention of irregularities and thus in averting damage to Franklin, its employees and customers. As far as the GDPR is applicable to the processing, the legal basis for this processing of personal data is Article 6 Paragraph 1 lit. f GDPR.
Data Controller
The data controller in the whistleblowing system is
Franklin Foods, Inc
2500 North Military Trail
Boca Raton, Florida 33431
Tel.: 1.561.638.7864
Website: www.franklinfoods.com
Further information can be found in the imprint of the website.
The data controller has appointed a data protection officer, whom you can reach at the following contact details:
Franklin Foods Inc
Data Protection Officer
zrice@franklinfoods.com
2500 North Military Trail
Boca Raton, Florida 33431
The whistleblowing system is operated by a company specialized in this field, EQS Group GmbH, Bayreuther Str. 35, 10789 Berlin in Germany, in the name and on behalf of Hochland SE. Hochland SE, as the parent company of the group, in turn provides Franklin with the system for receiving and processing notices concerning them.
Personal data and information entered into the whistleblowing system are stored in a database operated by EQS Group GmbH in a high-security data center. The data can only be viewed by Franklin. EQS Group GmbH and other third parties have no access to the data. This is guaranteed in the certified procedure by comprehensive technical and organizational measures.
All data is encrypted and stored with multi-level password protection and is subject to an authorization concept so that access is restricted to a very narrow circle of recipients. For its processing of personal data, EQS Group GmbH is subject to the very strict data protection regulations in the EU (especially the GDPR).
Franklin has appointed a data protection officer. Inquiries about data protection at Franklin can be sent to this person using the contact details listed above.
Type of the collected personal data
Use of the reporting system takes place on a voluntary basis. If you submit a report via the whistleblowing system, we collect the following personal data and information:
- your name, if you choose to reveal your identity,
- whether you are employed at Franklin, and
- the names of persons and other personal data of persons that you name in your report.
Confidential handling of reports
Incoming reports are received by a small selection of expressly authorized and specially trained employees of Franklin and are always handled confidentially. These Franklin employees will evaluate the matter and perform any further investigation required by the specific case.
During the processing of a report or the conduction of a special investigation it may become necessary to share reports with other Franklin employees or employees of other Group companies, e.g. if the reports refer to incidents in other Group companies. The latter may be based in countries outside the US, e.g. in the European Union or the European Economic Area with different regulations concerning the privacy of personal data. We always ensure that the applicable data privacy regulations are complied with when sharing reports.
All persons who receive access to the data are obligated to maintain confidentiality.
If it proves necessary to process your report or if it is required by law, state authorities, including law enforcement agencies, administrative authorities or courts, may also have access to this data.
Information of the accused person
As a basic principle we may be bound by law to inform the accused persons that we have received a report concerning them, unless this threatens further investigations into the report. In doing so, your identity as whistleblower is not revealed as far as is legally possible.
Rights of data subjects
As far as stipulated by data protection law, you and the persons named in the report might have the right to inquiry, rectification, erasure, restriction of processing and the right to object to processing of personal data concerning you/them. If the right of objection is claimed, we will immediately examine to what extent the stored data is still necessary for the processing of a report. Data that is no longer required will be deleted immediately. In addition, you also might have the right of lodge a complaint with a supervisory authority.
Retention period of personal data
Personal data is retained for as long as necessary to clarify the situation and perform an evaluation of the report or a legitimate interest of the company exists, or it is required by law. After the report processing is concluded, this data will be deleted in accordance with the statutory requirements.
Automated decision-making including profiling
Your personal data will not be used for automatic decision-making including profiling.
Use of the reporting portal
Communication between your computer and the reporting system takes place over an encrypted connection (SSL). Your IP address will not be stored during your use of the reporting portal. In order to maintain the connection between your computer and the BKMS® System, a cookie is stored on your computer that merely contains the session ID (a so-called null cookie). This cookie is only valid until the end of your session and expires when you close your browser.
It is possible of set up a postbox within the reporting system that is secured with an individually chosen pseudonym/user name and password. This allows you to send reports to the responsible Franklin employee either by name or in an anonymous, safe way. This system only stores data inside the reporting system, which makes it particularly secure. It is not a form of regular e-mail communication.
Notes on sending attachments
When submitting a report or an addition, you can simultaneously send attachments to the responsible Franklin employee. If you wish to submit an anonymous report, please take note of the following security advice: Files may contain hidden personal data that could compromise your anonymity. Please remove this data before sending. If you are unable to remove this data or are unsure how to do so, copy the text of your attachment into your report text or send the printed document anonymously to the address listed in the footer, citing the reference number received at the end of the reporting process.
Version: March 2021